October 5, 2015 United States Department ofTransportation Federal Aviation Administration Docket Management System 1200 New Jersey Avenue, NE Washington, DC 20590 Filed in www.regulations.gov 

# Akin 

# Gump
STRAUSS HAUER & FELD LLP

GREGORY S. WALDEN +1 202 .887.4213/fax: +1 202.887.4288 gswalden@akingump

.com

Re: Petition for Exemption ofLinking the World under Section 333 ofthe FAA Modernization and Reform Act, 49 U

.S

.C. 44701(f), and 14 C.F.R. Part 11 As counsel for and on behalf of Linking the World, we hereby seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(f) of the Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation Regulations, to allow Linking the World to operate the following unmanned aerial vehicles ("UAVs") to assist first responders in disaster response settings and in search and rescue operations: the senseFly eBee, the senseFly eXom, the Parrott BeBop, the 3D Robotics Aero-M, the 3D Robotics Iris+, the 30 Robotics X8-M, and the 3D Robotics Solo. Linking the World will comply with the standard conditions and limitations included in numerous Section 333 exemptions granted recently. Accordingly, we respectfully ask the FAA to grant this petition in summary fashion, and obviate Federal Register publication and public comment. Linking the World through Aid, Empowerment and Advocacy is an international NonGovernmental Organization ("NGO") that focuses on breaking the cycles ofpoverty through its programs to empower communities, its crisis response efforts, and the innovative way it leverages technology and new models ofcross-sector collaboration. Linking the World created the Help and Locate Operations ("HALO") program that utilizes UAVs and remote sensing platforms to provide NGOs and first responders with critical highvalue data for immediate situational awareness and significantly improved responsiveness in disaster response settings

. The HALO team typically arrives prior to first responders, gathering high

-value imagery, in real-time, to coordinate relief efforts, hazard analysis, and infrastructure weaknesses

. Traditional aerial Search and Rescue (" SAR") operations in traditional fixed-wing

Robert S

. Strauss Building 1333 New Hampshire Avenue, N.W

. Washington, D

.C

. 20036-1564 I 202.887

.4000 I fax 202

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.4288 1 akingurnp comLinking the Word Petition for Exemption October 5, 2015 Page 2 of7

aircraft and helicopters is cost prohibitive, while ground teams require significant ground resources and are limited in their coverage. The small, highly maneuverable UAVs with highresolution cameras allow us to conduct SAR activities for a fraction of the cost, risk and resources, both domestically and internationally. 

### The name ofthe applicant is Linking the World, 211 North Ervay, 4th floor, Dallas, Texas 75201. The primary contact is Mina Chang, ChiefExecutive Officer. Her telephone is 972 522 9189. Her email is mina.chang@linkingtheworld.org and Linking the World's web address is www.linkingtheworld.org. 

### Exemptions requested 14 C.F.R. Part 21 (airworthiness certification) 14 C

.F.R. Part 27 (normal category rotorcraft) 14 C.F.R. 61.113 (a) and (b) (pilot certification and qualification) 14 C.F.R. 91.7(a) (airworthiness) 14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions) 14 C.F.R. 91.405 (a) and (b) (maintenance) 14 C.F.R. 91.407(a)(l) (approval for return to service) 14 C.F.R. 91.409(a) (annual and airworthiness certification inspection) 14 C.F.R. 91.417(a) and (b) (maintenance records) 

### Safety equivalence or no adverse effect on safety Unmanned Aerial Vehicles and Systems Each of the UAVs Linking the World seeks authority to operate has been approved for commercial use in many section 333 exemptions to date

. Given their small size, operational capabilities, and the restricted areas in which the UAVs will operate, an exemption from Part 21 , Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted: these UAVs satisfy the equivalent level of safety as compared with manned aircraft and meet the criteria in section 333. Each UAV (with payload) is less than 55 pounds, carry no explosive materials or flammable liquid fuels , and would operate outside controlled airspace, with no passengers or crew on board. As the FAA has found in granting an exemption to Clayco, Exemption No

. 11109, at page 10: The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UAS for the aerial operations

.Linking the Word Petition for Exemption October 5, 2015 Page 3 of7

For the reasons outlined above, Linking the World also seeks an exemption from the certification requirements for normal category rotorcraft in Part 27. In support of Linking the World's request for an exemption from 14 C.F.R

. 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), Linking the World will adhere to the following inspection and maintenance program: it will inspect the UAS before and after each operation, as well as perform weekly, monthly, and annual inspections. Before each flight, the pilot in command will inspect the UAS to ensure it is in a safe condition for flight. The preflight inspection will account for any discrepancy, such as an inoperable component, item, or equipment. Linking the World will not initiate a flight ifthe inspection reveals a condition that adversely affects the safety ofoperations, and will not operate that UAS until it is found to be in a safe condition. Any UAS that has undergone maintenance or an alteration that affects the UAS's operation or flight characteristics will undergo a functional flight test before return to service

. Linking the World will follow the manufacturer's UAS requirements relating to components, maintenance, overhaul, replacement, inspection and life limits. It will record all maintenance, alterations, and the functional flight test in the UAS logbook, including total flight hours, description of work accomplished, and the signature of the UAS technician who returned the UAS to service. 1 Linking the World's UASs are equipped with an altimeter that provides the pilot with real-time telemetry data in addition to a constant digital display of altitude, speed, and UAS proximity

. Moreover, the UASs will be operated within the visual line ofsight ofthe pilot in command and observer and below 400 feet AGL. In addition, the flight controllers are programmed not to allow the aircraft to exceed the 400 feet ceiling, even ifthe pilot command input is in-conflict, or if communication with the remote control transmitter fails

. Accordingly, we do not believe an exemption from 14 C.F.R. 91.121 is required. In support ofLinking the World's request for an exemption from fuel requirements in 14 C

.F.R. 91.15l(a) and (b), we note that each UAS is battery

-powered and is operated for briefperiods of time, within the battery capacity ofthe UAS. UAV and UAS Operator Qualifications and Training In support of its request for an exemption from the pilot certification and qualifications requirements in 14 C.F.R. 61. l 13(a) and (a), Linking the World asserts that an equivalent level of safety is achieved by the DAS-specific experience ofits pilots

. Each pilot, before conducting a commercial operation under the requested exemption, will have performed at least 20 takeoffs and landings of the particular UAV, and flown the particular UAV for at least 5 hours. In

1 We believe the FAA has in its possession the manufacturer manuals for each UAS sought to be operated under the requested exemption. We will provide any manufacturer manual upon request.Linking the Word Petition for Exemption October 5, 2015 Page 4 of7

addition, each pilot will hold a valid and current private pilot, recreational pilot, or sport pilot certificate. UAV and UAS Operating Parameters Linking the World will operate its UASs in full compliance with the applicable manufacturer manual. All flights will be conducted within the visual line of sight ofthe pilot in command, within noncontrolled airspace

. Although the UAS may be operated in a metropolitan area, it will be controlled and monitored only by authorized personnel, and be flown below 400 feet AGL. Linking the World will also notify the appropriate Flight Standards District Office "("FSDO") and/or Air Traffic Control for any operation within five miles ofan airport. Linking the World will conduct a briefing before each day' s operations, which all personnel participating in the operations must attend. It will obtain written consent ofany person who will be participating in the operations or otherwise be on the private property where operations are to take place. It will limit its operations to daytime Visual Flight Rules ("VFR"). Linking the World seeks an exemption from the requirement in 14 C.F.R. 91.119, subsection (b), that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or structure in an area other than populated or congested, and not closer than 500 feet to any person, vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft operations in mind. While Linking the World may operate its UASs in a metropolitan area, the operations will be carefully pre-planned to minimize risk to persons or property, avoid intrusion into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a highly-congested area or open air assembly ofpersons. Linking the World will make every reasonable effort to ensure that no unauthorized person will be on the land over which the UASs will be operated, and will provide notice to adjacent buildings and furnish proctors as may be necessary to ensure that unauthorized persons do not come within the narrow parameters in which the UASs will be operated

. Combined with the technological capabilities ofthe UASs and that the UASs will be operated within the visual line of sight of the pilot and an observer, Linking the World submits that its operational limitations provides an equivalent level ofsafety to that provided in section 91.119. Public interest The proposed operations to assist in disaster response and search and rescue operations serve the highest public interest in saving lives, relieving hardships, and protecting real and personal property during natural as well as man-made disasters.Linking the Word Petition for Exemption October 5, 2015 Page 5 of7
Operating UASs under the limitations proposed by Linking the World will avoid any risk of harm to pilots as well as persons and people on the ground that would be present during the operation of manned helicopters. UAS operations will also require a much smaller energy footprint than with manned helicopters

. Operations limited to the United States Under the requested exemption, Linking the World will operate its UASs within the United States. Summary for FederalRegister Because petitioner seeks the same authority under the same conditions and limitations as the FAA has granted to many petitioners, we believe granting this petition would not set any precedent and thus should be subject to summary handling, thereby obviating publication ofa summary in the Federal Register and public comment.